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Detailed Privacy For Patients Policy

How the Suttons Medical Group uses your information to provide you with healthcare- Privacy Notice for Patients

This fair processing notice explains how the practice keeps your medical records confidential and complies with the General Data Protection Regulation (GDPR).

We hold your medical record so that we can provide you with safe care and treatment. We will also use your information so that the practice can check and review the quality of the care we provide. This helps us to improve our services to you. NHS health records may be electronic or on paper, usually a mixture of both and we use a combination of working practices and technology to ensure your information is kept confidential and secure.

Your GP practice records may include:

  1. your address, date of birth and contact details

  2. details of your appointments, home visits etc

  3. notes about your health and any conditions or illnesses you might have

  4. details about your treatment and care, including medications

  5. results of investigations or tests

  6. information from other healthcare providers
  • We will share relevant information from your medical record with other health or social care staff or organisations when they provide you with care. For example, your GP will share information when they refer you to a specialist in a hospital. Or your GP will send details about your prescription to your chosen pharmacy.

  • Healthcare staff working in A&E and out of hours care will also have access to your information. For example, it is important that staff who are treating you in an emergency know if you have any allergic reactions. This will involve the use of your Summary Care Record. For more information see: https://digital.nhs.uk/summary-care-records

  • The law requires The Suttons Medical Group to share information from your medical records in certain circumstances. Information is shared so that the NHS or Public Health England can, for example:

  • plan and manage services;

  • check that the care being provided is safe;

  • improve the quality and standard of care;

  • prevent illness and infectious diseases from spreading;

  • research into the development of new treatments.

  • We will share information with NHS Digital, the Care Quality Commission and Public Health England when the law requires us to do so. Please see below for more information.

  • We must also share your information if a court of law orders us to do so.

  • You have the right to object to information being shared for your own care. Please speak to the practice if you wish to object. You also have the right to have any mistakes or errors corrected.

Other important information about how your personal data is used to provide your healthcare

NHS Digital

  • NHS Digital is a national body which has legal responsibilities to collect information about health and social care services.

  • It collects information from across the NHS in England and provides reports on how the NHS is performing. These reports help to plan and improve services to patients

  • This practice must comply with the law and will send data to NHS Digital, for example, when it is told to do so by the Secretary of State for Health or NHS England under the Health and Social Care Act 2012.

  • More information about NHS Digital and how it uses information can be found at: https://digital.nhs.uk/home

  • All patients who receive NHS care are registered on a national database.

  • This database holds your name, address, date of birth and NHS Number but it does not hold information about the care you receive.

  • The database is held by NHS Digital

  • Telephone NHS Digital on: 0300 303 5678

  • NHS Digital sometimes shares names and addresses of patients suspected of committing immigration offences with the Home Office. More information on this can be found here: https://www.gov.uk/government/publications/information-requests-from-the-home-office-to-nhs-digital


Public Health

  • The law requires us to share data for public health reasons, for example to prevent the spread of infectious diseases or other diseases which threaten the health of the population.

  • We will report the relevant information to local health protection team or Public Health England.

  • For more information about Public Health England and disease reporting see: https://www.gov.uk/guidance/notifiable-diseases-and-causative-organisms-how-to-report


Care Quality Commission (CQC)

  • The CQC regulates health and social care services to ensure that safe care is provided.

  • The law says that we must report certain serious events to the CQC, for example, when patient safety has been put at risk.

  • For more information about the CQC see: http://www.cqc.org.uk/


National screening programmes

  • The NHS provides national screening programmes so that certain diseases can be detected at an early stage.

  • These screening programmes include bowel cancer, breast cancer, cervical cancer, aortic aneurysms, diabetic eye screening service and NHS health checks.

  • The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

  • More information can be found at: https://www.gov.uk/topic/population-screening-programmes

  • NHS health checks are carried out by the practice, anonymized data is processed by by Health Intelligence Ltd on behalf of the practice.


Safeguarding

  • Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm.

  • These circumstances are rare.

  • We would follow strict practice protocols and procedures in the event we needed to do this and would take professional advice from appropriate agencies.

  • We do not need your consent or agreement to do this.

  • Please see Lincolnshire wide policies for more information:

    https://www.lincolnshire.gov.uk/lsab/ - Adult safeguarding information

    https://www.lincolnshire.gov.uk/lscb/ - Safeguarding children information


Third Party Processors

The practice may use carefully selected third party service providers. When a third party service provider is used to process data on behalf of the practice there will always be an appropriate agreement in place to ensure that data is kept secure, that information is only used or shared in accordance with our instructions and that the provider operates appropriately. Functions carried out by such third party providers may include:

  • Companies that provide IT services and support. This includes our core clinical system, EMIS, which uses a third party hosted environment provided by Amazon Web Services. Your data remains in the UK at all times and is fully encrypted at all times.

  • Systems which manage patients facing services such as our website and services available via the website

  • Delivery services

  • Payment providers


Medicines Management

The Practice conducts Medicines Management reviews of medications prescribed or dispensed to its patients.

  • This review of prescribed medications ensures patients receive the most appropriate, up to date and cost effective treatments.

  • This service is provided to local practices by South Lincolnshire Clinical Commissioning Group via Optum.


Risk stratification

Risk stratification or data profiling tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission to hospital and identifying a need for preventive intervention.

  • Information about you is collected by a computer program from a number of sources including NHS Trusts or other health and social care services you have used as well as from this GP Practice.

  • A risk score is then arrived at through an analysis of your de-identified information using software managed by NHS Trusts and is only provided back to your GP as data controller in an identifiable form.

  • Information which identifies you will only be seen by this practice

  • Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness.

  • This means we can offer patients additional care or support as early as possible

  • Please note that you have the right to opt out of your data being used in this way.


Referrals Management

The Practice utilises the electronic Referral Facilitation Service commissioned for Lincolnshire practices from Optum. There is a formal Deed of Undertaking between Optum and Lincolnshire CCGs

  • The service support the referrals process and ensure that patients are cared for in the right setting at the right time.

  • The service facilitates most first outpatient appointments but excludes 2 week wait referrals

  • The service allows monitoring and review of referral patterns from practices as well as monitoring secondary care management of the workload. Such review will identify waiting times and irregularities in service provision.


Analytics and Research

Lincolnshire CCGs are working with Optum on a piece of analytic work to support the care and treatment of the Lincolnshire population.

  • A small number of Optum analytics specialists will have access to pseudonymised data. This means you cannot be identified and your anonymity is ensured

  • Your data will not leave the UK

  • Optum is fully compliant with all necessary data protection legislation.

  • Once the work is complete, all data will be destroyed

  • This Practice also contributes anonymous data to the Clinical Practice Research Datalink (CPRD)

  • Patients who have chosen not to share their data for these purposes will be excluded from the data extraction process.


Checking the quality of care - national clinical audits

The Suttons Medical Group contributes to national clinical audits so that healthcare can be checked and reviewed.

  • Information from medical records can help doctors and other healthcare workers measure and check the quality of care which is provided to you.

  • The results of the checks or audits can show where hospitals are doing well and where they need to improve.

  • The results of the checks or audits are used to recommend improvements to patient care.

  • Data are sent to NHS Digital a national body with legal responsibilities to collect data.

  • The data will include information about you, such as your NHS Number and date of birth and information about your health which is recorded in coded form - for example the code for diabetes or high blood pressure.

  • We will only share your information for national clinical audits or checking purposes when the law allows.

  • For more information about national clinical audits see the Healthcare Quality Improvements Partnership website: https://www.hqip.org.uk/ or telephone 020 7997 7370.

  • You have the right to object to your identifiable information being shared for national clinical audits. Please contact the practice if you wish to object.


CCTV

CCTV is installed at both surgery premises.

  • CCTV is used to ensure the security of the premises, prevention or detection of crime

  • CCTV is used to protect the safety of our staff whilst at work

  • Signs are displayed warning patients and staff that CCTV equipment is installed

  • CCTV images are monitored by practice staff in a secure area

  • CCTV images are retained for a limited period

  • Images of patients would not be disclosed without consent except in circumstances when this can be justified in the public interest. Personal and health information would not be released in any case.


We are required by law to provide you with the following information about how we handle your personal data.

Data Controller contact details

The Suttons Medical Group

Long Sutton Medical Centre
Trafalgar Square, Long Sutton
Lincolnshire PE12 9HB
Telephone: 01406 362081

Sutton Bridge Medical Centre
Railway Lane, Sutton Bridge
Lincolnshire PE12 9LP
Telephone: 01406 350217

Data Protection Officer contact details

The Data Protection Officer for Lincolnshire GP Practices is:

Judith Jordan, Arden & Gem Head of Integrated Governance
AGEM DPO
NHS Arden & Greater East Midlands Commissioning Support Unit
Westgate House, Market Street
Warwick CV34 4DE

Email: agem.dpo@nhs.net
Telephone: 0121 611 0730

Purpose of the processing

  • To give direct health care to individual patients.
  • To ensure correct people are invited for screening and that those most at risk will be offered treatment
  • To check and review the quality of care. (This is called Audit and clinical governance).
  • Compliance with legal obligations or court order

Lawful basis for processing

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under Article 6 and 9 conditions of the GDPR as set out below:

Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and

Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services...” and when

Article 6(1)(c)..’processing is necessary for compliance with a legal obligation to which the controller is subject…’

Healthcare staff will also respect and comply with their obligations under the common law duty of confidentiality, to protect your privacy at all times.

Recipient or categories of recipients of the processed data

The data may be shared with:

  • healthcare professionals and employed staff in the practice;
  • Other GPs
  • NHS trusts/Foundation Trusts/private hospitals
  • out of hours services;
  • emergency services;
  • diagnostic and treatment centres;
  • Independent contractors including opticians, dentists and pharmacists
  • Clinical Commissioning Group and Commissioning Support Unit
  • Optum, Health Intelligence Ltd and CPRD
  • Ambulance services;
  • Education Service
  • Community health services;
  • Mental Health Services;
  • Social Services;
  • Local authorities
  • Public Health England and national screening services;
  • CQC or General Medical Committee
  • NHS Digital and Health & Social Care Information Centre
  • Voluntary organisations eg MacMillan
  • The Police and Judicial Service

Right to access and correct

  • · You have the right to access your medical record and have any errors or mistakes corrected. Sometimes it may not be possible to amend information however a statement can be added to your record to explain that a particular piece of information is not accurate. Please speak to a member of staff.
  • We are not aware of any circumstances in which you will have the right to delete correct information from your medical record; although you are free to obtain your own legal advice if you believe there is no lawful purpose for which we hold the information and contact us if you hold a different view

Rights to object

  • You have the right to object to information being shared between those who are providing you with direct care. This may affect the care you receive – please speak to the practice.
  • You are not able to object to your name, address and other demographic information being sent to NHS Digital. This is necessary if you wish to be registered to receive NHS care.
  • You are not able to object when information is legitimately shared for safeguarding reasons. It is a legal and professional requirement to share information for safeguarding reasons. This is to protect people from harm.
  • There are very limited rights to object when the law requires information to be shared but government policy allows some rights to object
  • NHS Digital – you have the right to object to information being shared with NHS Digital for reasons other than your own direct care. You can object to your information being used for research and planning.

    Visit: www.nhs.uk/your-nhs-data-matters
  • NHS Digital sharing with the Home Office - There is no right of objection to NHS Digital sharing names and addresses of patients who are suspected of having committed an immigration offence.
  • Public health - Legally information must be shared under public health legislation. This means that you are unable to object.
  • Care Quality Commission - Legally information must be shared when the Care Quality Commission needs it for their regulatory functions. This means that you are unable to object.
  • Court order - Your information must be shared if it ordered by a court. This means that you are unable to object.
  • For national screening programmes: you can choose to no longer receive an invitation to a screening programme. See: https://www.gov.uk/government/publications/opting-out-of-the-nhs-population-screening-programmes

Notification

The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which personal and sensitive data is processed. This information is publicly available on the Information Commissioners Office website www.ico.org.uk

The Suttons Medical Group is registered with the ICO

Retention period

GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found at: https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016

or speak to the practice.

Right to complain

You have the right to complain to the Information Commissioner’s Office. If you wish to complain follow this link https://ico.org.uk/global/contact-us/

or call the helpline 0303 123 1113

Data we get from other organisations

We receive information about your health from other organisations which may be involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept up-to date when you receive care from other parts of the health service.

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